TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo November 19, 2020 Brian McKeag Chief Financial Officer HEARTLAND FINANCIAL USA INC 1398 Central Avenue Dubuque, Iowa 52001 Re: HEARTLAND FINANCIAL USA INC Form 10-Q for the Quarter Ended September 30, 2020 Filed November 5, 2020 File No. 001-15393 Dear Mr. McKeag: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-Q for the Quarter Ended September 30, 2020 Item 2. Management s Discussion and Analysis of Financial Condition and Results of Operations NON-GAAP Reconciliations Reconciliation of Adjusted Net Income Available to Common Stockholders and Adjusted Diluted EPS (non-GAAP) 1. We note that your disclosure of adjusted diluted earnings per share excludes provision for credit losses, a normal and recurring charge for your business. Please revise future filings to refrain from disclosing performance measures that exclude the provision for credit losses. See Question 100.01 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Brian McKeag HEARTLAND FINANCIAL USA INC November 19, 2020 Page 2 In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Lory Empie at 202-551-3714 or Cara Lubit at 202-551-5909 with any questions. FirstName LastNameBrian McKeag Sincerely, Comapany NameHEARTLAND FINANCIAL USA INC Division of Corporation Finance November 19, 2020 Page 2 Office of Finance FirstName LastName